Changing Markets Foundation
The Changing Markets Foundation partners with NGOs on market focused campaigns.
ID: 671932425498-56
Lobbying Activity
15 Jun 2017
DRAFT EC REGULATION ON THE APPLICATION OF CONTROL AND MITIGATION MEASURES TO REDUCE THE PRESENCE OF ACRYLAMIDE IN FOOD
We would like to thank you for the opportunity to submit comments on the draft regulation to reduce the presence of acrylamide in food ahead of a foreseen vote by Member States.
While we welcome that a number of improvements have been made with regards to previous versions of the draft regulation, we remain concerned that the draft measures contain a number of shortcomings that we fear will compromise its effectiveness. Most notably, the legislation still does not include maximum limits for acrylamide in certain food groups and the review clause, aiming to set these limits does not include a time-frame for this important improvement.
Further shortcomings of the draft measures:
• They do not set penalties for irresponsible food business operators with very high levels of acrylamide in their products nor they prevent the sale of such products until remediation has taken place, as the acrylamide benchmarks continue to be of a voluntary nature;
• They exempt all imported food products, as it does not seem possible for EU food safety authorities to inspect manufacturers operating outside the EU, when such products are found to contain high acrylamide levels;
• They continue to rely largely on industry’s self-monitoring, which - according to our recent analysis of EFSA’s data from 2015 - seems to be under-reporting information, where benchmark values are being exceeded; According to the industry statement, they have selectively sampled only the products, where voluntary mitigation measures were applied, which questions the credibility of their reporting.
• They only include simplified monitoring and testing requirements for all food businesses regardless of their size, such as colour screening, which may compromise the effectiveness of the proposed measures.
Our analysis of the results from official monitoring program, as reported to the European Food Safety Authority (EFSA) since 2007, confirmed that no significant reductions in the levels of acrylamide in food have been achieved since 2007. Over 2500 products, more than ten per cent of products tested during that time, were found to contain unacceptably high levels of acrylamide.
This lack of progress has been confirmed by our recent tests of foodstuffs in Belgium, France, Germany and the United Kingdom. These have shown that food products with high levels of acrylamide continue to be placed on the market, yet measures to reduce acrylamide have been known to food manufacturers since 2006. In this context, it is particularly unacceptable that despite acrylamide exposure being a major concern for infants and young children,, our tests show that a significant proportion of baby biscuits placed on the market exceed the European benchmark (10% in the UK alone) and high acrylamide levels are associated with certain products from food majors such as Nestlé.
We continue to believe that only the introduction of legally binding limits for acrylamide in foods will be effective in protecting European consumers, including those most vulnerable, from being exposed to unacceptably high levels. This is why we call on European legislators to listen to almost 250,000 Europeans who are calling on you to put people before profits and include ambitious legally binding reduction objectives in the proposed legal measures.
Yours sincerely,
Nuša Urbančič
Campaigns Director, Changing Markets
Eoin Dubsky
Campaign Manager, SumOfUs
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